Original Issuance Date: June 30, 2020
Last Revision Date: January 3, 2025
1. Policy Purpose
In accordance with federal regulations, universities are required to disclose state-specific professional licensure or occupational certification information to students or prospective students based on the state in which a student is located. This policy is necessary to provide a general structure under which universities shall determine a student’s location. Adherence to federal regulations is a condition of Title IV eligibility.
2. Responsible UW System Officer
Vice President for Academic and Student Affairs
3. Scope and Institutional Responsibilities
This policy applies to all UW universities and their academic programs leading to professional licensure or occupational certification, regardless of mode of delivery.
4. Background
In 2023, the U.S. Department of Education released federal regulations related to the offering of distance education and requirements for state authorization, notifications, and disclosures. Federal regulations require universities to create a written process for determining a student’s location for both Title IV verification purposes as well as state-specific disclosures related to whether the academic programs meet the professional licensure or occupational certification requirements in states where prospective and enrolled students are located, regardless of modality.
5. Definitions
Time of Initial Enrollment: Unless otherwise defined by federal law, and for the purposes of this policy, a university may consider the time of initial enrollment as a student’s official enrollment in a professional licensure or occupational certification program and/or the receipt of the student’s financial commitment to the first class, semester or term required for completion of a licensure program.
Location: At the time of initial enrollment in a professional licensure or occupational certification program, a student’s location shall be defined as the following:
- A student who enrolls in a program that holds instruction primarily at a physical location on campus (on-campus instruction) shall be considered located in the state of Wisconsin. This determination is based on the student being located (in part or exclusively) in Wisconsin when receiving instruction and enrolling in a program designed, primarily, to lead to licensure in the state of Wisconsin.
- A student enrolling in a program that offers instruction in a hybrid learning format will be considered located in Wisconsin.
- A student enrolling in a program offered exclusively through distance education will be considered located at their current address listed on the official application and/or acceptance into the program.
Professional Licensure or Occupational Certification Program: An educational program that is designed to meet educational requirements for a specific professional licensure or occupational certification that is required for employment in an occupation or is advertised as meeting such requirements.
6. Policy Statement
Universities are required to determine the states in which their students and prospective students are located for the purpose of disclosing state-specific professional licensure or occupational certification information. Universities shall establish a written process to determine a student’s location at the time a prospective student seeks information about an academic program leading to professional licensure or occupational certification, or a student enrolls in, and/or an existing student notifies the institution of a change of address, for purposes of issuing the required federal disclosures as to whether the university’s academic program, regardless of modality, fulfills the professional licensure or occupational certification requirements of states in which the prospective student or enrolled student is located. This written process shall include, at minimum, the following:
- A written process as to how a student’s location is determined;
- A documented change of address process for currently enrolled students and timeframe for disclosing any academic program requirement changes if a student has moved to a different state; and
- A consistent application of these policies and procedures regarding student location to all students, including students enrolled in face-to-face programs.
7. Related Documents
8. Policy History
First Revision: January 3, 2025
First approval: June 30, 2020
9. Scheduled Review
January 2030